GR L 61236; (January, 1984) (Digest)
G.R. No. L-61236 January 31, 1984
NATIONAL FEDERATION OF LABOR and ZAMBOOWOOD MONTHLY EMPLOYEES UNION, ITS OFFICERS AND MEMBERS, petitioners, vs. THE HONORABLE CARLITO A. EISMA, LT. COL. JACOB CARUNCHO, COMMANDING OFFICER, ZAMBOANGA DISTRICT COMMAND, PC, AFP, and ZAMBOANGA WOOD PRODUCTS, respondents.
FACTS
Petitioner union filed a notice of strike against private respondent Zamboanga Wood Products, Inc., alleging unfair labor practices, including illegal termination and non-payment of allowances. A strike commenced on May 23, 1982. Subsequently, the company filed a complaint for damages with a prayer for a preliminary injunction in the Court of First Instance of Zamboanga City, presided over by respondent Judge Carlito A. Eisma. The complaint alleged that striking union members blockaded the road leading to the company’s manufacturing division, obstructing ingress and egress. Petitioners moved to dismiss the complaint, contending that the acts complained of were incidents of picketing arising from a labor dispute and, therefore, fell under the exclusive jurisdiction of the Labor Arbiter pursuant to Batas Pambansa Blg. 227. Respondent Judge denied the motion to dismiss and issued an ex-parte order temporarily restraining the union members from obstructing the company’s property.
ISSUE
Whether a regular court or a labor arbiter has jurisdiction over a suit for damages filed by an employer against a union, where the alleged acts of obstruction are incidents of picketing during a strike.
RULING
The Supreme Court granted the petition, ruling that the Labor Arbiter has exclusive jurisdiction. The legal logic hinges on the interpretation of Article 217 of the Labor Code, as amended. The Court traced the legislative history: the original Article 217 vested labor arbiters with jurisdiction over all money claims and other benefits arising from employer-employee relations. Presidential Decree No. 1367 later temporarily removed claims for moral and other forms of damages from their jurisdiction, vesting it in regular courts. However, Presidential Decree No. 1691, and subsequently Batas Pambansa Blg. 130, which was in force at the time of the suit, restored the original jurisdiction. Specifically, Article 217(a)(2) and (5) conferred upon labor arbiters exclusive original jurisdiction over “all money claims of workers” and “all other claims arising from employer-employee relations.”
The complaint for damages filed by the employer, alleging obstruction due to picketing, is indisputably a claim arising from employer-employee relations. The act of picketing is a legitimate concerted activity in connection with a labor dispute. Any illegal acts allegedly committed during such picketing, including obstruction, are intrinsically related to the strike and thus fall within the ambit of labor disputes over which labor arbiters exercise specialized expertise. Consequently, the regular court had no jurisdiction to entertain the suit. The order of the respondent Judge was issued without jurisdiction and with grave abuse of discretion. The temporary restraining order issued by the Supreme Court was made permanent, and the respondent Judge was prohibited from further proceeding with the civil case.